Does Microsoft Copilot Studio sign a BAA?

Yes, it signs a BAA

Microsoft says Copilot Studio is covered under its HIPAA BAA, which commercial customers who are covered entities or business associates get by default through the Data Protection Addendum. Copilot Studio is still not intended for use as a medical device.

Based on 2 sources, all from Microsoft unless marked.

Business associate
Microsoft
Tool
Microsoft Copilot Studio
Plans with a BAA
Copilot Studio (commercial Online Service licenses)
Checked
Signs a BAA
Microsoft signs a BAA for Microsoft Copilot Studio.

By plan

PlanBAAHow to get itConditions
Copilot Studio (commercial Online Service licenses)Signs a BAAIncluded in the termsThe Microsoft BAA comes by default through the Online Services Data Protection Addendum for HIPAA covered entities and business associates. Copilot Studio agents can collect and handle PHI when the organization is bound by HIPAA.[1],[2]

Are the AI features covered?

Vendors often sign a BAA for the core product but leave some AI features out. Here is what Microsoft says about each one.

AI featureUnder the BAADetails
Copilot Studio agents (conversations capturing health information)CoveredMicrosoft's examples include agents that ask for and capture health details such as blood pressure or weight.[1]
Web search / Bing grounding and external connectorsNot statedThe Copilot Studio compliance page lists no exclusions, and the data-handling pages for web search could not be fetched.[1]

Sources

  1. Review ISO, SOC, and HIPAA compliance - Microsoft Copilot StudioMicrosoft, Documentation. Checked Oct 11, 2026.
  2. HIPAA/HITECH - Microsoft complianceMicrosoft, Documentation. Checked Oct 11, 2026.

A signed BAA is necessary but not sufficient for HIPAA compliance, which also depends on configuration, access controls, and your own policies. Verdicts summarize the vendor's own published terms as of the date checked; confirm with the vendor and your counsel before sending protected health information. Not legal advice.